OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 1, 1991

Mr. Riley H. Mayhall, Jr.
M & M Consulting
14130 Old Columbia Pike
Burtonsville, Maryland 20866

Dear Mr. Mayhall:

This is in response to your July 3, 1991, request for clarification of whether the Occupational Safety and Health Administration's (OSHA) regulations addressing motor vehicles apply to end dump trucks operating on jobsites and on public highways between jobsites. We apologize for the delay in responding to your inquiry.

Please be advised that all end dump trucks operating between jobsites on the public highways must comply with all the provisions of 29 CFR 1926.601 when the trucks enter off-highway jobsites. However, if there is a conflict between these regulations and those of the U.S. Department of Transportation (DOT), then the DOT regulations have precedence while the trucks are operating on the public highways.

With respect to your question concerning the meaning of the term "other devices" used in 29 CFR 1926.601(b)(11), please be advised that it means any system specifically designed by the manufacturer to prevent accidental tripping or operating of the haulage body hoist or dump mechanism. Such a system may consist of a hydraulic interlock, an electric interlock, or a spring activated lever lock.

If we can be of any further assistance, please contact [by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.]

Patricia K. Clark, Director
Directorate of Compliance Programs
[Corrected 08/16/2007]

July 3, 1991

Mr. Gerald P. Reidy, Director
U.S. Department of Labor
Office of Construction & Maritime Compliance Assistance
Division of Construction
200 Constitution Avenue, N.W.
Room 3610
Washington, D.C. 20210

SUBJECT: Clarification of CFR 29, Part 1926.601 Applicability

REFERENCE: Our Telephone Discussion on July 1, 1991

Dear Mr. Reidy:

It is requested that the applicability of the subject regulation be clarified in writing and forwarded to this requester as soon as possible.

The unclear area to this requester is: Do all end dump trucks operating between jobsites on the public highways have to comply with the subject regulation when they enter an off-highway jobsite? If so, do all of the (b) General requirements apply including (b),(11). Also, in (11) the term "other device" and what would comply with this requirement? If you could cite examples of the "other device" it would be helpful.

Thank you for your time and consideration in this matter. If any additional information is required please call the undersigned.



Riley H. Mayhall Jr.